Therap and the Release of Information

As the QA Director, Therap Administrator, and one of the few that can spell HIPAA (no it isn’t spelled HIPPA), I was assigned the additional duties of HIPAA Privacy Officer, HIPAA Security Officer, HIPAA Compliance Officer, and HIPAA Training Officer.  So I went to HIPAA School and got educated.  With my suitable for framing HIPAA certificate in hand, I started building procedures for various HIPAA issues.  One of the first I tackled was release of information (ROI).

This blog isn’t going to be about HIPAA, but rather some thoughts on how to release Protected Health Information stored in Therap.  In my agency we serve primarily minor children so most of the discussion is going to be based on the parent requesting information or filling out an ROI.  Whether it is a parent, guardian, or individual served (client) submitting the ROI the idea is the same.  So here goes:

In my mind I separate the information we store on the individuals we serve into two categories.  The first category is what I think of as relatively static, it doesn’t get updated frequently, and doesn’t change day to day.  In Alaska we have a Plan of Care as the primary document determining the kind and amount of services an individual will receive at our agency.  And there are other documents containing diagnosis, family contact information, application for Medicaid waiver, Care Coordination/Case Management assignment, and acknowledgement statements for HIPAA, agency policies, and a host of other paperwork required to get services at our agency.  Despite my continuing efforts most of this information continues to be stored on paper files vice in Therap.  However, whether it is stored in Therap or on paper it is a finite amount of data, usually not requiring too space.  Since it is information parents usually provide us or sign for us, rarely is it the object for a ROI.  If it is requested this information is easily copied, printed and provided.

However, once an individual has been receiving services with us for six months or so, the amount of information stored in Therap is HUGE!  For example, we have individuals who get four detailed ISP Data inputs daily, including weekends.  To provide all of this information for an ROI can be a major undertaking.  That is going to be my focus.

My first step is try to figure out the who, what, and why of the ROI.  In my short term as the agency HIPAA guru these are the broad categories of ROIs I’ve addressed:

  • Involved Parent.  The involved parent is just trying to keep abreast of the services their child or dependent is receiving.  At my agency we are very much in favor of enabling the parent to have access to daily records to read the daily events.  Pre-Therap our agency had the parents sign the individual paper note prior to turning them in.  During the transition from paper notes to Therap one of the key points raised by the parents was visibility to the daily notes.  To give the same visibility to the daily notes the parents had with paper notes, we gave Therap access to each parent/guardian.  There was some significant work giving every parent/guardian (mother, father, step parent and guardian in some cases) access as we transitioned to Therap but it was what the parents asked for.  Each involved parent was given a Therap User account, read only, to view their child’s Therap entries.  In practice, most parents (97%) lost interest after a brief period and quit checking notes.  Now we only give that level of access to parents/guardians if they requested it.  Giving a parent a Therap account, Therap training, and access to their child’s information is our preferred solution to answer a ROI by a parent/guardian.  There is no cost to the agency or parent/guardian for this ROI.
  • Parent Requesting Bulk Data.  For a variety of reasons occasionally we have parents submitting a ROI for data covering a long period.  This is where a little detective work is needed to figure out what the parent/guardian is really looking for.  Sometimes the parent/guardian just want to know that the agency is responsive to their needs.  With a little hand holding and training, giving the parent Therap access will work.  Sometimes it isn’t the daily notes that are the concern but rather a trend of improvement is more what the parent is looking for.  In that case the answer is an easy report to generate from Therap and it usually will meet their needs.  In addition we are happy to teach parents how to print individual notes from Therap or export bulk data to Excel.  We are also happy to export the data at the office and burn it to a CD/DVD or copy it to a thumb drive they provide.  However, the real challenge is the parent with little or no computer skills.  For parents without confident computer skills giving them Therap access (or reports) is not going to work.  They want paper!  Now what format should we provide the data?  The parent’s typical expectation is something that looks like the paper notes they received prior to our move to Therap and electronic notes.  Therap will let you print out individual notes that the parent is looking for.  But when the parent wants all the notes from the start of the fiscal year, printing out individual notes is going to be very time consuming.  Again I ask what is the information going to be used for, the answer helps me better provide what they want.  If all they want is the basics of what type service and when, we provide them ISP data exported to Excel.  But if they want the information to justify additional or different services they will need detailed data exported to Excel.  A typical example is a family wanting to justify broadening their home and community based services to include nursing.  In this case the family asked for paper copies of all the Therap notes for the current fiscal year, about 5 months worth of data.  Their child receives a variety of services with us and usually has three to four Therap notes per day.  We determined the most efficient means of providing the information they wanted was ISP Data with a detailed export to Excel, then that spreadsheet was organized, sized, and printed for the parent.  A five minute discussion with the parent of how the data was displayed usually ensured they were happy with what they received.  HIPAA regulations state that parents have an absolute right to the information, and that we cannot charge for the man-hours required gather or print the information, but we can charge for the cost of the copies.  So, while the agency could bill the parent for the cost of copies, we don’t.  Our copier/printer company charges us 1.4¢ a page for black and white copies and we buy many cases of paper reams. So, in this case, a 300 page report would cost us approximately $6 and is not worth the time and effort to try to collect.  And for our computer challenged parents, who have been with us for a long time and remembered paper notes, billing them any amount for computer generated information would be an insult and a potential reason to move to another agency.
  • Parent Requesting Release to Third Party.  Again for a variety of reasons we have parents who want their child’s information to be released to a third party.  If a parent wants to provide information to another agency, or their physician, or another type of medical agency, they rarely really want each and every day habilitation note for the last three years, for example.  I usually start with a phone call to the third party to try and find out what type of information they want and in what format.  Most other agencies and physicians are happy with basic data or a report that shows a trend of data, rather than each and every note.  And, thankfully, they usually want it in some type of electronic format.  After the phone call it is a no brainer to provide the data.  However, since we provide services to children, occasionally we get a ROI during a custody battle.  Again, I call the third party to try to figure out what type information they are looking for and in what format.  But some of those phone calls have taken an ugly turn.  One particular law office seemed to think I was trying to hide something and forcibly insisted they had a right to have a copy of “each and every sheet of paper.”  …So I oblige them…  You want all the ISP data for the last two and half years, with a detail export to Excel?  You got it.  For the parents in the above paragraph I spend time working on making sure it is readable, the unused columns are deleted, and I show them how to read it.  For the law office I just put all the columns on one page and hit print.  As for billing, for other agencies and physicians we provide it for free as a professional courtesy.  For that difficult law office… HIPAA allows me to charge them for our actual cost.  Now how much is my time and effort worth?  Not only cost of each piece of paper, but wear and tear on the printer, cost of electricity for the machine and the lights, heat in the building, part of our rent, small piece of our annual Therap bill…  Oh my, I had an enormous bill for them…  But cooler heads prevailed, and pointed out that the law office would just pass the cost off to the parent, with a hefty percentage added.  We charged them for our employee’s wages and the cost of paper and printing.

My bottom line is that with a phone call ahead of time, most ROIs are more accurately and easily handled.

Happy Holidays!

Rob

 

By |2016-11-03T10:15:19+00:00December 14th, 2013|Categories: Rob Sterling's Posts|Tags: , , , , , , , |Comments Off on Therap and the Release of Information

Training and Quality

We all know the critical link between training and quality of services, as well as quality of documentation. It takes a lot of training and follow up to ensure your staff give you what you need to meet state and federal requirements. You need a keen eye as a quality assurance staff member to catch errors, fill gaps, and communicate the necessity of good documentation.

Having said that, many providers are using different techniques to train their staff, both in the classroom and online. Making sure that all of your personnel have been trained accordingly is a fundamental need for all quality assurance.

For your consideration, we are offering a session open to Certified Trainers and the Quality Assurance Special Interest Group on looking at tools to both help with training, as well as managing all of that information.

Lorelei Glenn will be discussing this on November 22 at 1PM EST. She has been doing some research about Learning Management Systems (LMSs) versus Training Management Systems (TMSs). Lorelei put it this way, “In our organization, many people were confused between LMS and TMS – thinking that TMS was an LMS solution. We are currently looking into implementing an LMS that will work with Therap’s TMS (interface). We have reviewed about 10 different LMS’s, and imported Therap SCORM trainings (which was super cool) as well as our own SCORM formats. Most of the systems allow a CSV export, which can then be used to import into Therap’s TMS. An LMS can often be implemented with low or no cost, especially for small providers.”

An invitation has been sent to all current members of the Special Interest Group. To join, click here.

Happy October!

Allison

By |2016-11-03T10:15:20+00:00October 19th, 2013|Categories: Events|Tags: , , , , , , , , |Comments Off on Training and Quality

Overlapping Time

It has always been an issue from a Quality Assurance stand point for time to overlap in the system for our organization. Although the new option that has been added to the ISP program to not allow for overlapping time, it still does not stop time between two different programs from overlapping. We meet every week on correcting time that overlaps or time that has gaps between programs. We spend a great deal of time combing through hundreds of entries every week to find this information, and even sorting in Excel can be confusing to look at. I would be interested in learning of other ways to address this issue if anyone has ideas.

By |2013-06-10T18:31:16+00:00June 10th, 2013|Categories: Kristy Dominy's Posts|Tags: , , |Comments Off on Overlapping Time

Knowledge is Power

Ken Slavin did a nice overview of changes within HIPAA and HiTECH, as well as reviewing the meaning surrounding CCHIT’s and ONC’s definitions of EHRs.

Video on Trainings for Certified Trainers: A Discussion about HiTECH, HIPAA, and CCHIT

By |2013-03-15T20:24:45+00:00March 15th, 2013|Categories: Allison's Posts|Tags: , , , , , , , , , , , , , , , , , , , , , |Comments Off on Knowledge is Power

NM Regional Conference and Policy

As a certified trainer I have the privilege of leading sessions at our regional conference. This role makes me feel like a true Therap geek, as I get super excited to talk about things in the system and help people brainstorm to find the best way for the system to work for them. My husband was teasing me the night before the conference as he saw me pack my certified trainer bag and I did feel a bit silly that I was so excited. But then I was able to lead some good discussions and share more of Therap with many people today.

One of my sessions (which I get to teach again tomorrow) was on policy development as it relates to Therap. I wanted to do this session here in NM after I attended a similar session at the national conference this past Feb. It is truly helpful to see how many agencies are approaching policy development and what topics others believe are necessary to address in their policies. Here is a list, albeit incomplete, of some we discussed today: electronic signatures and sign up agreements, Internet usage, staff usage of Therap off hours, ensuring agency policy agrees with state policy, QA/QI and incident management/review, sharing of documents and data with team members outside of your agency…

Often we discover that we need a policy or procedure after the fact. Many policies end up being developed as a response to a problem or issue discovered and then solved. We would love to learn from your history. If you’ve developed new policies at your agency in connection to Therap in some way or if you have policy thoughts/comments, please share. Thanks!

Therap, as a Tool Toward Quality Assurance!

About two weeks ago, I had the privilege of representing our company on a committee meeting to discuss “Quality Assurance” among all service providers of both residential and day program service agencies. The meeting was conducted by the Division of Developmental Disabilities (DDD). As the topic clearly suggests, the main goal of this committee was to ensure that, despite budget cuts at state level, with the inevitable consequences of reduced funding for the division, and consequently the deep cuts to rates paid to service providers, quality service can still be maintained.

As the discussions progressed, it became apparent to me that Therap can be a tool to help meet that objective. Here is the reason why: after using Therap for all these many years, I have come to know that for the most part, staff document what they have really done. In most cases they under-document. For those who may falsify what they actually did, it does not take that long before they are discovered. Because, when one makes a false claim, other staff will soon see that what was done is not what was reported.

A good example is where someone writes a t-log stating they swept, mopped and took out trash from a resident’s apartment. If that was not so, the incoming staff are going to see that it is not true and they are going to write about it. Since everyone reads what the t-log says, it becomes apparent to the staff who falsified information that their inaction was discovered and they can not report similar falsehoods without actually having done the job.

Therefore, the Therap system becomes not only a tool to ensure staff do what they are supposed to do and at the same time an evaluation tool for supervisors to tell, in part, who is doing what they are supposed to do, thus assuring quality service to the consumer. In retrospect, using Therap helps foster honesty, accountability and quality assurance.

By |2016-11-03T10:15:42+00:00May 9th, 2012|Categories: Francis Sumba's Posts|Tags: , , |Comments Off on Therap, as a Tool Toward Quality Assurance!

Patience

“A handful of patience is worth more than a bushel of brains”

I found myself thinking about all of the things we can do in Therap and want our agency to do more and more!   Then I realized that our agency is the largest provider in Ct and I really need to relax a bit, and have some “Patience”!   Good things come in time!!

Here in CT, we are having our next CT User Group Meeting on March 15th, 2pm, at Oak Hill’s Campus in Hartford.  If you need some additional information, email me at julianm@ciboakhill.org. It is a nice time to share your wealth of knowledge within Therap!

Had a wonderful time at the conference in NJ in February.   I really enjoyed being in a hotel by myself and no one asking me to feed them, do laundry, and do homework, but don’t tell! I did have to lose 10lbs after those 3 days!

I really liked the Training Management Section and this is next on our list!  I am setting it up this month and any suggestions or helpful tips would be greatly appreciated from anyone out there using the system.  We are not using the entire section of having staff signing up for trainings, but we will be using this for staff to alert them when their training is due.  Think this would be great and  it will help staff from lapsing in their training when it is sitting right there on their First Pg!

Our agency’s motto is “Consistency” and we are currently doing alot of training for Supervisors, RN’s, and Behaviorists!    The ISP section has been working well and Supervisors enjoy the Individual List Pg!  RN’s are finishing entering medications and are working on getting everyone using the Appointment Section in Health Tracking.  Behaviorists are working on ISP’s for mood and anxiety scales, reinforcement schedules, and getting everything on Therap!  No More Paper!  Yeah!

So, I guess I need to have some “Patience”, it will all work out in the end!  We will get there!

Enjoy this weather, we have been very lucky this winter, just 2 snowstorms and one of them was before Halloween.  Amazing!

Mary Beth Julian-Supervisor, Oak Hill, Hartford, CT

 

 

By |2016-11-03T10:15:44+00:00March 9th, 2012|Categories: Mary Beth Julian's Posts|Tags: , , , |Comments Off on Patience

Tracking Timeliness of ISP Data Inputs

The first of March, another beautiful day in Eagle River.  Forecast high temperature 26 degrees, forecast low temperature 20 degrees… Current temperature zero degrees…  Our Alaskan weathermen never get it right.

FOCUS joined the Therap family to eliminate paper notes.  Our Direct Support Providers had a habit of hanging on to the paper notes and turning them in bunches.  As the stories go, they often had coffee stains, spilt cereal, creamed carrots, and other biological hazards spread across them.  It wasn’t unusual for staff handling the paper notes to be using universal precautions; you know, gloves, surgical mask, and HAZMAT bins.  With Therap we no longer have to keep our shot records up to date just to read the notes our Providers write. 

However, since our Providers need to access a computer to write their notes, they often are unable to complete the notes immediately.  While with paper notes our Providers had a habit of hanging on to them and turning them in bunches, with Therap some of our Providers have a habit of writing their notes in bunches.  Unfortunately, some are submitting the ISP Data for the services they provided very time late, three to four weeks in one extreme case.  Of course this adds to the difficulty in billing and payroll.  My concern is, since I can’t remember what I had for breakfast, how can the Providers write accurate notes for services they provided so long ago?

When I do a performance review with any of our Providers, I always check the timeliness of their ISP Data submission to ensure it is within our standard.  Took me a while to figure out how to do it in quickly and accurately.

In an ISP Data Search you can check an individual ISP Data Collection entry.  In the blue field at the top is a date / time stamp for when the data was submitted.  That can be compared against the date the services were provided to determine how time late the entry was made.  However, that is data for a single note and does not indicate a trend or average over a broader time frame.  To get that trend or average the data can be exported to Excel.  Unfortunately, that date / time stamp is not included during an export to Excel.

In an Activity Tracking Search you can search by Provider for a given time frame (no more than one month) to see when they submitted ISP Data.  Each line of data cannot be accessed in this search; but the data can be exported to Excel.  However, it will not give the date the services were provided; just the date the entry was made.

Now we have two separate Excel spreadsheets; one with the date services were provided and the other with the date the data was submitted.  How do we combine them to get at the length of time between the time the services were provided and when the Therap ISP Data was submitted?

The secret is that both spreadsheets contain the Form ID number.  With the Form ID number to connect the date the service was provided and the date the ISP Data was submitted it is a relatively simple process to use the “Lookup” function (I used “vlookup”) to put all the needed data on one spreadsheet.  With the data on one spreadsheet, the data can then be easily manipulated to determine how late the data was submitted and any average or trends you may be interested in.

This of course is just an overview of how I do it.  If you need help with the details, just let me know.

By |2012-03-01T20:55:56+00:00March 1st, 2012|Categories: Rob Sterling's Posts|Tags: , , , , , |Comments Off on Tracking Timeliness of ISP Data Inputs
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